The word 'substantial' in s 10AA(2)(a) of the Land Tax Management Act 1956 (NSW) negates the proposition from [name withheld] and [name withheld] that scale is irrelevant to whether a business of primary production is undertaken on land. Whether a use has a substantial commercial purpose or character is at least in part a relative judgment requiring comparison with other uses. Cattle operations that can never generate a profit on any commercial measure, conducted on high-value industrially-zoned land with minimal time and resources, do not satisfy s 10AA(2)(a).
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